REC Proposes Criteria for Translator, LPFM Coexistence

LPFM proponent REC Networks has proposed an approach that it believes will allow the FCC to evaluate both LPFM and FM translator applications, to ensure that some LPFMs can fit within much of a proposed translator’s service contour.

REC Founder Michelle Eyre made a recent filing to Docket 99-25. REC put forth a requirement calling for the availability of at least two LPFM stations within 70% of the proposed translator’s 60 dBu service contour. Translators that meet that can be granted, according to Eyre, though “many of these applicants will still have to dispute issues of mutual exclusivity with other pending translator applicants.”

Some 12,000 FM translator applications were filed in the 2003 Auction 83 window, according to REC, including “thousands” from two commonly owned entities. It says 3,200 have been granted and another 6,400 translator applications remain pending.

In 2010, Prometheus Radio Project reached an understanding with Educational Media Foundation to allow LPFM applications to file on top of translator applications if there is a demonstrated community need for local LPFMs. This was also in response to the FCC’s limit of 10 translator applications per applicant.

“While at the time, REC supported a cap on translator applications, we thought that 10 was too restrictive,” writes Eyre in the filing. “REC had proposed a ‘point’ system where there was a cap that was weighted to support the use of local/nearby stations while discouraging ‘distant’ translators.”

Some LPFM proponents, including REC, feel that granting thousands of translator applications limits the future availability of LPFM stations in many major markets. That’s why REC has proposed the requirement to allow at least two LPFMs within the 60 dBu contour of a translator in some cases. The proposal, REC feels, meet the “community need” standard of the Local Community Radio Act of 2010.

Eyre calls it the “2 x 70” plan. In tech terms: “REC’s criteria to determine future LPFM availability is within the predicted service contour (based on antenna patterns, power and RCAMSL filed in the short form and then with HAAT calculated from FCC terrain data), that at least 70% of the census block groups (based on population) measured at the designated centroid can receive a minimum of two LP-100 channels (spaced at least two channels apart) based on current rules plus an elimination of third-adjacent channels for domestic stations. Applications where there are no centroids within the service contour are automatically considered as meeting criteria.”